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HomeMy WebLinkAboutDSHW-2024-009440 DAQE-AN154380001-17 May 26, 2017 Trevor Murray LaPoint Recycle and Storage PO Box 146 Lapoint, UT 84039 Dear Mr. Murray: Re: Approval Order: New Produced Water and Solids Treatment Facility - LaPoint Recycle and Storage Project Number: N15438-0001 The attached document is the Approval Order for the above-referenced project. Future correspondence on this Approval Order should include the engineer's name as well as the DAQE number as shown on the upper right-hand corner of this letter. The project engineer for this action is Mr. Todd Wetzel, who may be reached at (801) 536-4429. Sincerely, Bryce C. Bird Director BCB:TW:jf cc: TriCounty Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 www.deq.utah.gov Printed on 100% recycled paper State of Utah GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality APPROVAL ORDER: New Produced Water and Solids Treatment Facility - LaPoint Recycle and Storage Prepared By: Mr. Todd Wetzel, Engineer Phone: (801) 536-4429 Email: twetzel@utah.gov APPROVAL ORDER NUMBER DAQE-AN154380001-17 Date: May 26, 2017 LaPoint Recycle and Storage Produced Water Facility Source Contact: Trevor Murray Phone: (435) 247-2377 Email: lapoint.recycle.storage@live.com Bryce C. Bird Director Abstract LaPoint Recycle and Storage (LaPoint) has requested a new AO for its produced water and solids treatment facility. Produced water is received by truck from oil and gas operations. The water then undergoes phase separation using tanks and centrifuges for the recovery of oil and condensate. The remaining water is then discharged into evaporation ponds. Water entering the evaporation ponds remains until it has been evaporated to the atmosphere. Recovered oil and condensate is stored on site in tanks prior to being trucked off site for sale. In addition to the produced water operations the facility will treat contaminated soils received from spills and other oil and gas production operations. The contaminated soils will be land applied, watered, and tilled regularly to minimize emissions to the atmosphere. The source is located in Uintah County, which is an unclassified area for ozone and an attainment area for all other criteria pollutants. NSPS (40 CFR 60 Subparts A and IIII) and MACT (40 CFR 63 Subparts A and ZZZZ) regulations apply to this source. NESHAP (40 CFR 61) regulations do not apply to this source. This facility is considered a minor source, as all VOC and HAP emissions associated with the evaporation ponds are considered fugitive. The accumulation of point source equipment on-site does not exceed the 100 tpy criteria emission threshold or the combined HAP limit of 25 tpy or single HAP limit of 10 tpy and as such Title V of the 1990 Clean Air Act does not apply to this source. The potential emissions, in TPY, will be as follows: PM10 = 0.34, PM2.5 (subset of PM10) = 0.16, NOx = 6.18, SO2=2.04, CO = 2.47, VOC (including VOC listed HAPs) = 223.01, HAPs (including Methanol) = 106.62, Methanol = 101.21, and CO2e = 2,407. This air quality AO authorizes the project with the following conditions and failure to comply with any of the conditions may constitute a violation of this order. This AO is issued to, and applies to the following: Name of Permittee: LaPoint Recycle and Storage PO Box 146 Lapoint, UT 84039 Permitted Location: Produced Water Facility NW-NE Sec 12 T5S R19E Lapoint, UT 84039 UTM coordinates: 607,216 m Easting, 4,473,267 m Northing, UTM Zone 12 UTM Datum: NAD83 SIC code: 1389 (Oil & Gas Field Services, NEC) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] DAQE-AN154380001-17 Page 3 I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 LaPoint Recycle and Storage Produced Water and Solids Treatment Facility II.A.2 Evaporation Ponds II.A.3 Landfarm Treatment of contaminated soil II.A.4 Seven (7) Storage Tanks Maximum capacity: 400 bbl (each) All controlled by combustor II.A.5 Two (2) Separation Tanks Maximum capacity: 900 bbl (each) All controlled by combustor II.A.6 Tank Heaters Maximum rated capacity: less than 5.0 MMBtu/hr (each) Fuel: Propane II.A.7 Mechanical Separation Equipment Electric heater loops Quantity: Two (2) centrifuges Control: Combustor II.A.8 One (1) Combustor Controls: All storage tanks and the mechanical separation equipment II.A.9 Generator Engine Fuel: Diesel Maximum engine rating: 750 kW NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ DAQE-AN154380001-17 Page 4 II.B Requirements and Limitations II.B.1 Source-Wide Requirements II.B.1.a The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-8] II.B.1.b Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive source on site to exceed 20% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-201-3] II.B.2 Produced Water Requirements II.B.2.a The owner/operator shall not exceed 53.89 tons of combined GRO + DRO emissions (where GRO shall be considered the measurement of organics in the C6 - C10 range and DRO shall be considered the measurement of organics in the C11 - C28 range) from water sent to the evaporation ponds per rolling 12-month period. [R307-401-8] II.B.2.b The owner/operator shall not exceed 5.30 tons of combined HAP emissions (excluding methanol) from water sent to the evaporation ponds per rolling 12-month period. [R307-401- 8] II.B.2.c To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using data from the previous 12 months. Combined VOC (GRO + DRO), HAPs, and methanol emissions shall be calculated using the following formulas: VOC (tons) = (water volume) x (VOC + BTEX sampled concentrations) HAPs (tons) = (water volume) x (BTEX sampled concentrations) Methanol (tons) = (water volume) x (methanol sampled concentrations) Records of the water received shall be kept for all periods when the plant is in operation. The water volume received shall be determined on a daily basis using billable receipts. Sample requirements are described in Condition II.B.2.d. Records of methanol emissions shall be kept on a monthly basis for informational purposes only. [R307-401-8] II.B.2.d Sampling of processed water shall be collected and analyzed, at a minimum, once monthly. The sample shall be collected, handled, and analyzed as follows: A. Sample shall be collected at the outfall of the treatment process prior to water being discharged into the evaporation ponds. B. Sample shall be no less than 8 oz. in volume. C. The sample shall be analyzed no less than 7 days after collection. Samples shall be stored at a temperature no less than 32 °F and no more than 40 °F prior to analysis. DAQE-AN154380001-17 Page 5 D. Samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10), TPH-DRO (C11 - C28), and using appropriate EPA methods such as Method 8260 or 8015, or another EPA approved method as acceptable to the Director. [R307-401-8] II.B.2.e The owner/operator shall maintain a water temperature within the pre-discharge tank greater than or equal to 100 oF. [R307-401-8] II.B.2.e.1 To determine compliance with the pre-discharge tank temperature the owner/operator shall maintain a daily log of the water temperature. [R307-401-8] II.B.3 Landfarm Requirements II.B.3.a The owner/operator shall not exceed 61.05 tons of combined VOC and HAP emissions from processed soil per rolling 12-month period. [R307-401-8] II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Combined VOC and HAPs emissions shall be calculated using the following formula: tons VOC and HAPs/month = (soil volume) x (soil density [2,200 lbs/yrd3]) x (GRO + DRO sampled concentrations) x (0.6 atmospheric emission rate) Records of the soil received shall be kept for all periods when the plant is in operations. The soil volume received shall be determined on a daily basis using billable receipts, if centrifuged solids are also processed on site this volume shall be determined by the loader. The records for received soil shall be kept on a daily basis using billable receipts. The records for centrifuged solids shall be kept on a daily basis using loader volumes of soil removed. Sample requirements are described in Condition II.B.3.b. [R307-401-8] II.B.3.b Initial sampling for all received soils shall be done prior to any land application. The sample shall be collected, handled, and analyzed as follows: A. Sample shall be as representative of the load as possible and be taken after any soil amendments and adjustments. B. Sample shall be no less than 8 oz. in volume. C. The sample shall be sent off for analysis or frozen within 24 hours after collection. Frozen samples shall be stored until 20 samples are collected, or 30 calendar days have expired whichever comes first, at which point the samples can be combined to generate a single composite sample to be sent off for analysis. D. Samples shall be analyzed for TPH-GRO (C6 - C10) and TPH-DRO (C11 - C28) using appropriate EPA methods such as Method 8260 or 8015, or other EPA approved testing methods approved by the Director. [R307-401-8] II.B.3.b.1 To determine compliance with soil sampling, the owner/operator shall keep record of all soil sample analytical results while the plant is in operations. [R307-401-8] DAQE-AN154380001-17 Page 6 II.B.3.c The owner/operator shall spread and disk/till the waste soil within 72 hours after receipt when conditions permit. [R307-401-8] II.B.3.c.1 If conditions prohibit the application of waste soil within the allotted time frame, a record must be kept for every occurrence and what conditions caused the exceedance. [R307-401-8] II.B.3.d Prior to land application of any soils, the owner/operator shall treat the soil as follows to maximize biodegradation: A. Amend the soil as needed by adding bacterial inoculate, nutrients, and/or soil amendments B. Adjust water content above 5% C. Adjust pH to above 6 and below 8 D. Take two (2) representative 8 oz. soil samples from below the soil surface and freeze for sample analysis [R307-401-8] II.B.3.d.1 To determine compliance with soil amendments, prior to land application the owner/operator shall keep records of the following: A. Dates soil received, treated, and applied B. Plot where soil is applied C. Water content of the soil, measured by handheld probe D. pH of soil, measured by handheld probe E. Quantity of nutrients and soil amendments added to the soil, if any [R307-401-8] II.B.3.e The owner/operator shall disk/till/turn the soil to a minimum of the following, when weather conditions permit: A. At least once per week for the first 30 days after application B. At least once per month for the first 6 months [R307-401-8] II.B.3.e.1 To determine compliance with disking/tilling operations, the owner/operator shall keep records of all disking/tilling operations. Records shall include the following: A. Location B. Date of all disking/tilling operations C. If weather conditions prohibit disking/tilling operations a record of the specific conditions shall be kept [R307-401-8] DAQE-AN154380001-17 Page 7 II.B.3.f The owner/operator shall use water applications on all operational areas to reduce fugitive dust emissions as well as maintain adequate moisture content to facilitate biological degradation of hydrocarbons. [R307-401-8] II.B.3.f.1 To determine compliance, records of water application shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date treatments were made B. Location of treatments and quantity of water applied C. Rainfall amount received, if any [R307-401-8] II.B.4 Tank Requirements II.B.4.a The owner/operator shall not produce more than 15,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period. [R307-401-8] II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the last day of each month using the most recent 12 months of sales data recorded via sales receipts. Records of crude oil sales shall be kept for all periods when the site is in operation. Crude oil sales shall be kept on a daily basis. [R307-401-8] II.B.4.b Centrifuge solids shall be land applied or transferred off site on the day they are removed from the centrifuge. [R307-401-8] II.B.4.c Secondary containment located under and around centrifuge shall have no standing crude oil or solids present at any time. [R307-401-8] II.B.4.d The owner/operator shall load and unload all tanker trucks on site by the use of submerged loading. [R307-401-8] II.B.4.e The owner/operator shall keep the storage tank thief hatches closed and latched except during tank loading, unloading, or other maintenance activities. [R307-401-8] II.B.4.f The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief hatches are closed, latched, and the associated gaskets are in good working condition. Records of thief hatch inspections shall include the date of the inspection and the status of the thief hatches. [R307-401-8] II.B.5 Combustor Requirements II.B.5.a All exhaust gas/vapors from all storage tanks on site shall be routed to the operating combustor within 120 days from the issuance of this AO. [R307-401-8] II.B.5.b The combustor shall operate with a continuous pilot flame and be equipped with an operational auto-igniter. [R307-503-4] II.B.5.c The combustor shall operate with no visible emissions. [R307-401-8] II.B.5.c.1 Visual determination of smoke emissions from the combustor shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] DAQE-AN154380001-17 Page 8 II.B.6 Generator Engine Requirements II.B.6.a A non-resettable hour meter shall be installed and operated on the generator engine. [R307- 401-8] II.B.6.b The generator engine shall be limited to 1560 hours of operation per rolling 12-month period. [R307-401-8] II.B.6.b.1 To determine compliance with the rolling 12-month total the owner/operator shall calculate a new 12-month total by the last day of each month using the data from the previous 12 months. The hours of operation for the month shall be determined by subtracting the previous months hours from the current months hours as shown on the meter. The records shall be kept on a monthly basis. [R307-401-8] II.B.6.c The sulfur content of the diesel fuel burned in the generator engine shall not exceed 15 ppm by weight. [R307-401-8] II.B.6.d The sulfur content shall be determined by ASTM Method D-4294-89, or approved equivalent. Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. [R307-401-8] II.B.7 Haul Road Requirements II.B.7.a The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive Emission and Fugitive Dust sources on site. [R307-205] II.B.7.b Visible emissions from haul roads and fugitive dust sources shall not exceed 20% opacity. [R307-205-4] II.B.7.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall use procedures similar to Method 9. The normal requirement for observations to be made at 15-second intervals over a six-minute period, however, shall not apply. Visible emissions shall be measured at the densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle. [R307-401-8] II.B.7.c A maximum haul road speed limit of 15 miles per hour shall be posted, at a minimum, at the beginning of the haul road where it is clearly visible. [R307-401-8] II.B.7.d All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed to control fugitive dust. The application of water shall be used except when the ambient temperature is below freezing. Treatment shall be of sufficient frequency and quantity to meet the opacity limits listed in this AO, or as determined necessary by the Director. [R307-401-8] II.B.7.d.1 Records of water treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date of treatment B. Number of treatments made C. Records of temperature if the temperature is below freezing [R307-401-8] DAQE-AN154380001-17 Page 9 Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines PERMIT HISTORY This AO is based on the following documents: Is Derived From NOI dated January 29, 2015 Incorporates Additional Information dated March 31, 2015 Incorporates Additional Information dated November 23, 2016 ADMINISTRATIVE CODING The following information is for UDAQ internal classification use only: Uintah County CDS B MACT (Part 63), Unclassified Area, NSPS (Part 60) DAQE-AN154380001-17 Page 10 ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document: 40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a) HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year UAC Utah Administrative Code VOC Volatile organic compounds